Worldwide: Transfer Pricing

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Tax law and international tax law thought leadership, articles, podcasts, videos and webinars from expert sources across the legal world. Explore insights covering topics such as capital gains tax, corporate tax, income tax, inheritance tax, national insurance, property taxes, sales taxes, VAT, GST, tax authorities, transfer pricing and withholding tax.

Transfer Pricing Issues When Dealing With Trusts, Foundations, And Similar Arrangements

While most transfer pricing rules will apply to large multinational enterprise (MNE) groups, family offices, foundations, and trusts cannot ignore them.

United States Tax

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NERA

EU Tax Directives #6 Repeal Of 3 Proposed EU Tax Directives - New York Office Snippet

Loyens & Loeff New York regularly posts ‘Snippets' on a range of EU tax and legal topics. Earlier this calendar year, our ‘EU Tax Directives Series' offered practical, concise summaries of key EU tax directives...

United States Tax

LL

Loyens & Loeff

Commentary On New Canadian Transfer Pricing Legislation

The November 4, 2025, Canadian federal budget introduced new Canadian transfer pricing legislation containing the most consequential change since 1997.

United States Tax

RP

Ruchelman PLLC

What Landmark Israeli Transfer Pricing Case, Hexadite Ltd. v. Israel Tax Authority, Means For U.S. Multinationals

The Israeli District Court decision in Hexadite Ltd. v. Israel Tax Authority provides important lessons on transfer pricing, valuation of intangibles, and post-acquisition business-model changes.

United States Tax

RS

Rotfleisch & Samulovitch P.C.

FAQ: How Tax And Tariff Changes Are Impacting Manufacturing CFOs

United States Tax

MG

MGO CPA LLP

U.S. Tax Shifts And Tariff Volatility: What Manufacturing CFOs Need To Know

United States Tax

MG

MGO CPA LLP

U.S. Reporting Requirements For Cross-Border, Related-Party Transactions: What U.S. Taxpayers Must Know Now For Compliance

United States Tax

RS

Rotfleisch & Samulovitch P.C.

A&M Middle East Tax & Customs Newsletter | Fall Edition

AM

Alvarez & Marsal

Why The IRS Just Made It Easier To Reduce BEAT Exposure On Intercompany Services

United States Tax

MG

MGO CPA LLP

トランプ関税への対応と移転価格への影響

United States Tax

JD

Jones Day

Still Fourth Down And Goal For Medtronic Transfer Pricing Case

United States Tax

RP

Ruchelman PLLC

Tax Law Changes That Should Trigger Referrals For Your Clients

United States Tax

KR

Kaufman Rossin

How To Align Your Global Supply Chain And International Tax Strategy

United States Tax

MG

MGO CPA LLP

5 Quick Questions For Referrers: How Specialty Tax Adds Value For Your Clients

United States Tax

KR

Kaufman Rossin

How The JAMS AI Rules Can Streamline Discovery For AI-Related Disputes

United States Litigation

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JAMS

Top 5 Takeaways From "Advanced Mediation Strategies For Handling The Toughest Situations"

United States Litigation

J

JAMS

USPTO Proposes Dramatic Restrictions For Inter Partes Review Institution

United States IP

OB

Osha Bergman Watanabe & Burton LLP

Food Venture Financing News – Weekly Issue No. 264

United States Commercial

DW

Davis Wright Tremaine

Back To School 2025: Title IX Updates And How ADR Can Help Universities Resolve Disputes (Podcast)

United States Litigation

J

JAMS

Frequently Asked Questions About International Tax And Supply Chain Realignment

Cross-border supply chain changes can trigger exit taxes, compliance penalties, and tax inefficiencies if not planned with international tax in mind.

United States Tax

MG

MGO CPA LLP

Amendments To The German Regulation On The Attribution Of Profits To Permanent Establishments (Betriebsstättengewinnaufteilungsverordnung) Relating To Insurance Permanent Establishments

On 6 August 2025, the German Federal Ministry of Finance has published a ministerial draft containing several amendments to existing tax regulations.

United States Tax

AM

Alvarez & Marsal

Eaton's Loss To IRS Sparks Concerns Over EU Privacy Compliance

A recent federal appeals court ruling giving the IRS access to data in a transfer pricing dispute has the potential to put multinational companies on a collision course with stringent European Union privacy laws.

European Union Privacy

KR

Kaufman Rossin

Navigating Q2 2025: Essential Income Tax Accounting Insights

As companies finalize their Q2 2025 reporting, tax departments are once again navigating a shifting landscape of legislative and regulatory change. The centerpiece of this quarter's developments was the advancement...

AM

Alvarez & Marsal

A First Sale Doctrine Checklist: Six Phases For Successful Tariff Reduction

United States International

HS

Harris Sliwoski

Trump Signs Sweeping Tax Bill Into Law, With Major Implications For Corporate Clients Worldwide

United States Tax

CL

Carter Ledyard & Milburn

IRS Workforce Losses Pose Growing Risk To Businesses Amid Tariff-driven Tax Complexity

United States Tax

WR

Wiley Rein

PER-10/PJ/2025, New Procedures For Tax Information Exchange

AM

Alvarez & Marsal

Section 899: Potential Tax Increases For Canadians Investing In The U.S.

United States Tax

GW

Gowling WLG

Navigating Tariffs And Income Taxes And Transfer Pricing

United States Tax

JD

Jones Day

Trade, Tariffs, And Tax Effects: Deal-Maker Considerations For Diligence And Structuring

United States International

R

Riveron

IRS Transfer Pricing Guidance: Adjustments Based On Actual Results

United States Tax

CD

Caplin & Drysdale

Three International Tax Cases Practitioners Must Watch In 2025

United States Tax

KR

Kaufman Rossin

Navigating BEAT And Transfer Pricing: Strategies To Minimize U.S. Tax Liability

United States Tax

MG

MGO CPA LLP

Trade, Tariffs, And Tax Effects: Deal-Maker Considerations For Diligence And Structuring

Riveron's M&A Tax and Transaction Services experts have observed the latest changes and evolving trends related to US trade and tariff policies and have participated in several discussions on the potential impacts.

United States International

R

Riveron

IRS Transfer Pricing Guidance: Adjustments Based On Actual Results

The IRS has issued guidance endorsing a muscular approach to the application of "periodic adjustments" provisions. Those provisions authorize IRS adjustments of a taxpayer's pricing for transfers of high-value intangibles, including platform contribution transactions, for taxable years after the year of transfer, based on the actual, realized profitability of those intangibles in those later years

United States Tax

CD

Caplin & Drysdale

Three International Tax Cases Practitioners Must Watch In 2025

Federal courts next year are set to decide several cases that could shape how international tax planners will account for uncertainty and enforcement risks in 2025 and beyond.

United States Tax

KR

Kaufman Rossin

Navigating BEAT And Transfer Pricing: Strategies To Minimize U.S. Tax Liability

Companies can reduce BEAT liability by reclassifying payments, capitalizing costs into COGS, or restructuring contracts to limit related-party payments.

United States Tax

MG

MGO CPA LLP

Hooray For New Math: Is It Really A Simplified Transfer Pricing Approach For 2025?

United States Tax

RP

Ruchelman PLLC

Contract Manufacturing: Considerations For Transfer Pricing In France

In the Bloomberg 2024 Transfer Pricing Forum, Senior Managing Director Emmanuel Llinares and Delsol Avocats Partner Julien Monsenego explain considerations for the transfer pricing of contract manufacturing

United States Tax

N

NERA

Thoughts On The Amount B Framework: Considerations For Contributions Within And Beyond The Baseline Scope

On 19 February 2024, the OECD/G20 Inclusive Framework on BEPS released its final report on Amount B of Pillar One, "Special Considerations for Baseline Distribution Activities."

United States Tax

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NERA

IRS Issues Final Rules On Intangible Property Repatriations

With the allure of tax incentives for foreign derived intangible income and an increase in foreign audits scrutinizing transfer pricing, bringing intellectual property (IP) back to the United States...

United States Tax

MW

McDermott Will & Emery

Essential Guide To Transfer Pricing For Your Multinational Business

As a multinational enterprise setting up operations in the United States, it is imperative for you to understand the complexities of transfer pricing and intercompany transactions.

United States Tax

MG

MGO CPA LLP

Kilgour V Commissioner Of Taxation [2024] FCA 687: Regrettably On Arm's Length Terms

United States Tax

AM

Alvarez & Marsal

CFOs: Prepare Your Company For IRS Transfer Pricing Audits And Mitigate Risk

United States Tax

MG

MGO CPA LLP

The Aftermath Of Ya Global: Who Is A Partner?

United States Tax

RP

Ruchelman PLLC

Transfer Pricing: Insights For The Alternative Investment Industry

United States Tax

ML

Marcum

Tax Year 2024 Changes, Planning For Businesses To Consider

United States Tax

KR

Kaufman Rossin

So You Think You're In Control: When Do Transfer Pricing Rules Apply?

United States Tax

CD

Caplin & Drysdale

How Intercompany Agreements Can Mitigate Transfer Pricing Risk

United States Tax

MB

Mayer Brown

Proposed Dual Consolidated Loss Rules: More Traps For The Unwary

United States Tax

AM

Alvarez & Marsal

Supreme Court Opens The Doors To Federal Court Challenges To Treasury And IRS Regulations

United States Tax

SJ

Steptoe LLP

Business Plan For Hollister's India Entry Strategy And Manufacturing Setup

United States Healthcare

Nexdigm USA

Project Management For Winding Down Operations In India

United States Media & IT

Nexdigm USA

Entity Management And Finance, Tax, And Corporate Compliance Support

United States Tax

Nexdigm USA

Finance Function Transition And Management For The Client's Indian Operations

United States Technology

Nexdigm USA

The GenAI Revolution In Biology And Biotech

United States Tax

AM

Alvarez & Marsal

Trademark Royalty Free Agreements Tax Considerations

United States IP

G.A.M. Law Office

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Latest Videos

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The Trouble With Transfer Pricing For Foreign Parents And US Subsidiaries (Video Content)

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ArentFox Schiff

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